DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claim(s) 1-5, 9-11, 13-16, and 20 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Gupta (12,069,794).
Regarding Claim 1: Gupta teaches a system for blocking access to high temperature components, the system comprising: a computer component (140); and a shape memory alloy (SMA) interlock (180) thermally coupled to the computer component (fig. 1), wherein the SMA interlock is configured to autonomously deform (col. 3 lines 24-31 and col. 1 line 52 col. 2 line 18) to prevent access to the computer component when a temperature of the computer component exceeds a threshold temperature (col. 3 lines 24-31 and col. 1 line 52 – col 2 line 18).
Regarding Claim 2: Gupta teaches a cover (160) positioned over the computer component (fig. 1).
Regarding Claim 3: Gupta teaches the SMA interlock is configured to, when the temperature of the computer component exceeds the threshold temperature, lock the cover in place (col. 3 lines 24-31).
Regarding Claim 4: Gupta teaches the SMA interlock is configured to, when the temperature of the computer component falls below the threshold temperature, disengage from the cover (col. 5 lines 36-52).
Regarding Claim 5: Gupta teaches the SMA interlock is configured to allow access to the computer component when the temperature of the computer component falls below the threshold temperature (col. 5 lines 36-52).
Regarding Claim 9: Gupta teaches further comprising a thermal interface material (TIM) (150) positioned between the computer component and the SMA interlock (fig. 1).
Regarding Claim 10: Gupta teaches the computer component comprises a heatsink (fins of 160).
Regarding Claim 11: Gupta teaches the computer component comprises a server (col. 12 lines 49-56).
Regarding Claim 13: Gupta teaches the threshold temperature is based on the computer component (col. 5 lines 36-52).
Regarding Claim 14: Gupta teaches an apparatus for blocking access to high temperature components, the apparatus comprising: a cover (160) configured to block access to a computer component (fig. 1); and an engaging component (170) comprising a shape memory alloy (SMA) material (180), wherein the engaging component is configured to autonomously deform (col. 3 lines 24-31 and col. 1 line 52 col. 2 line 18) to couple to the cover (fig. 1) based on a temperature of the engaging component exceeding a threshold temperature (col. 5 lines 36-52).
Regarding Claim 15: Gupta teaches wherein coupling, by the engaging component, to the cover includes locking the cover in place (fig. 1 through 170 and 180), thereby preventing access to the computer component (fig. 1 and col. 5 lines 36-52).
Regarding Claim 16: Gupta teaches wherein the engaging component is configured to uncouple from the cover based on the temperature of the engaging component falling below the threshold temperature (col. 5 lines 36-52).
Regarding Claim 20: Gupta teaches the threshold temperature is based on the computer component (fig. 1 and col. 5 lines 36-52).
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claim(s) 6-8 and 17-19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Gupta (12,069,794) in further view of Gupta (11,589,481).
Regarding Claim 6: Gupta (‘794) lacks a specific teaching wherein the SMA interlock comprises a copper aluminum nickel alloy.
Gupta (‘481) teaches wherein the SMA interlock comprises a copper aluminum nickel alloy (col. 10 lines 41-61).
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta (‘794) by having teaches wherein the SMA interlock comprises a copper aluminum nickel alloy as disclosed by Gupta (‘481) in order to allow for a more reliable source of materials for the component to engage and work in the way required to help increase the heat dissipating qualities of the overall apparatus which in turn decreases the chance of the apparatus overheating which in turn could damage components to require repair or replacement to the internal components of the overall apparatus.
Regarding Claim 7: Gupta (‘794) lacks a specific teaching of wherein the SMA interlock comprises a nickel titanium alloy.
Gupta (‘481) teaches wherein the SMA interlock comprises a nickel titanium alloy (col. 10 lines 41-61).
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta (‘794) by having the SMA interlock comprises a nickel titanium alloy as disclosed by Gupta (‘481) in order to allow for a more reliable source of materials for the component to engage and work in the way required to help increase the heat dissipating qualities of the overall apparatus which in turn decreases the chance of the apparatus overheating which in turn could damage components to require repair or replacement to the internal components of the overall apparatus.
Regarding Claim 8: Gupta (‘794) teaches the SMA interlock comprises a component (180) configured to expand (col. 5 lines 20-52) when the temperature of the computer component exceeds the threshold temperature (col. 5 lines 20-52), but lacks a specific teaching of the component being a pin.
Gupta (‘481) teaches the SMA interlock comprises a pin (172 in fig. 5 is considered to be in a pin type shape).
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta (‘794) by having the SMA interlock comprising a pin as disclosed by Gupta (‘481) in order to allow for a better connection between the cover, heat sink, and computer component in order to decrease the chances of thermal disconnection between the components which would decrease the heat dissipation qualities of the overall apparatus which could cause the apparatus to overheat which in turn could damage components to require repair or replacement to the internal components of the overall apparatus.
Regarding Claim 17: Gupta teaches wherein the engaging component comprises a component (180) configured to expand (col. 5 lines 20-52) when the temperature of the engaging component exceeds the threshold temperature (col. 5 lines 20-52) but lacks a specific teaching of the component being a pin.
Gupta (‘481) teaches the engaging component comprises a pin (172 in fig. 5 is considered to be in a pin type shape).
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta (‘794) by having the engaging component comprising a pin as disclosed by Gupta (‘481) in order to allow for a better connection between the cover, heat sink, and computer component in order to decrease the chances of thermal disconnection between the components which would decrease the heat dissipation qualities of the overall apparatus which could cause the apparatus to overheat which in turn could damage components to require repair or replacement to the internal components of the overall apparatus.
Regarding Claim 18: Gupta (‘794) lacks a specific teaching wherein the SMA interlock comprises a copper aluminum nickel alloy.
Gupta (‘481) teaches wherein the SMA interlock comprises a copper aluminum nickel alloy (col. 10 lines 41-61).
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta (‘794) by having teaches wherein the SMA interlock comprises a copper aluminum nickel alloy as disclosed by Gupta (‘481) in order to allow for a more reliable source of materials for the component to engage and work in the way required to help increase the heat dissipating qualities of the overall apparatus which in turn decreases the chance of the apparatus overheating which in turn could damage components to require repair or replacement to the internal components of the overall apparatus.
Regarding Claim 19: Gupta (‘794) lacks a specific teaching of wherein the SMA interlock comprises a nickel titanium alloy.
Gupta (‘481) teaches wherein the SMA interlock comprises a nickel titanium alloy (col. 10 lines 41-61).
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta (‘794) by having the SMA interlock comprises a nickel titanium alloy as disclosed by Gupta (‘481) in order to allow for a more reliable source of materials for the component to engage and work in the way required to help increase the heat dissipating qualities of the overall apparatus which in turn decreases the chance of the apparatus overheating which in turn could damage components to require repair or replacement to the internal components of the overall apparatus.
Claim(s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Gupta (12,069,794).
Regarding Claim 12: Gupta lacks a specific teaching of a second computer component and a second SMA interlock thermally coupled to the second computer component, wherein the second SMA interlock is configured to prevent access to the second computer component when a temperature of the second computer component exceeds a second threshold temperature different from the threshold temperature.
It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the apparatus of Gupta by having a second computer component and a second SMA interlock thermally coupled to the second computer component, wherein the second SMA interlock is configured to prevent access to the second computer component when a temperature of the second computer component exceeds a second threshold temperature different from the threshold temperature in order to allow for an expansion of the heat dissipation qualities of the computer system which would prevent further damage to the overall system which in turn would decrease the need for repair or replacement of components to the system. This can be accomplished merely by duplication the already disclosed elements of the claim wherein it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co.. V. Bemis Co., 193 USPQ 8.
Response to Arguments
Applicant's arguments filed 4/27/2026 have been fully considered but they are not persuasive. In regards to claims 1 and 14 the applicant merely argues that the SMA washers of Gupta are not coupled to the BGA device and does not autonomously deform when a temperature of the BGA device 130 exceed a threshold temperature while the examiner respectfully disagrees. In regards to the argument of the washers not being coupled to the BGA device, as per fig. 1 it can clearly be seen that the washers 180 are a part of the overall heat dissipation device which is coupled to the BGA device through the multiple components of the system. In regards to the washers not autonomously deforming when a temperature of the BGA device 130 exceed a threshold temperature it is clearly taught by Gupta and shown in the rejections above that when the temperature is too high the SMA washers will deform to a different shape. It is noted by the examiner the terminology used is autonomously wherein the accepted definition being used to interpret this language would be “denoting or performed by a device capable of operating without direct human control”. In regards to claims 1-5, 9-11, 13-16, and 20 the applicant merely states Gupta does not teach these limitation and the examiner respectfully disagrees. In regards to claims 6-8 and 17-19 the applicant argues the prior art of Gupta (‘481) does not teach the SMA element being thermally coupled to the computer component as well as the other limitations of claim 1 and 14. This argument is considered moot as the prior art of Gupta (‘481) was not used to reject any of these limitation and was used as support for specific types of materials that can be used for shape memory alloys. Therefore from the rejections above and the response to these arguments the claims are considered as finally rejected.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. The prior art cited in the Notice of References Cited PTO-892 but not relied upon above are considered related as they include teachings of shape memory alloys in the use of electronic devices.
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANTHONY MICHAEL HAUGHTON whose telephone number is (571)272-9087. The examiner can normally be reached M-F 9a-5p.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Imani Hayman can be reached at 571-270-5528. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ANTHONY M HAUGHTON/Primary Examiner, Art Unit 2841
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